Reviewing your lending institution’s collateral protection policies may not be at the top of your priority list. Who really wants to scour through the fine print of a policy that could easily exceed one hundred pages? These cumbersome policies are contracts that spell out the obligations of both the insurer and the insured using complex language and technical jargon which can be difficult to interpret. Due to the assignment of responsibilities to both parties, it is vital to take the time to understand your policies and the obligations outlined within.
While many lenders are familiar with blanket coverages designed to eliminate the need to track and force-place insurance on mortgage and titled portfolios, fewer may be familiar with an alternative blanket coverage designed to protect the lender’s commercial equipment portfolio in cases of lapsed insurance coverage.
Last month, Santander Consumer USA reached a settlement with the Consumer Financial Protection Bureau (CFPB) over a GAP product that all auto lenders should be aware of. For background, you should know that the Consumer Financial Protection Bureau (CFPB) first took steps to regulate GAP coverage in 2012. Furthermore, the Dodd-Frank Act gave the CFPB supervisory authority over “larger participants” of certain markets for financial products or services, as the CFPB defines by rule.